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HMRC internal manual

Double Taxation Relief Manual

Czechoslovakia: Interest

Article 11(1) provides that interest arising in Czechoslovakia to a United Kingdom resident who is the beneficial owner of the income is taxable only in the United Kingdom.

However, Czechoslovakia retains its taxing rights over the interest if it is effectively connected (see INTM153110 fifth sub-paragraph) with a permanent establishment or fixed base which the United Kingdom resident recipient has in Czechoslovakia. In such a case, the provisions of the Business profits Article or the Independent personal services Article, as appropriate, will apply.